AOG Shelbyville TN, KSYI--Solved and Home!

[EricJ]

12 minutes ago, MikeOH said:

The reason I ask is I would love to make this kind of repair and properly log it.  My concern is, once I've logged it, some anal IA at a future annual may tell me it's invalid as I am NOT an A&P.  I want to be able to point at 'chapter and verse'...one can try and use the Coleal LOI but that one is subjective and an anal IA could still give me grief!

Yup.   This is why getting an A&P/IA that will work with you is important if you want to do more stuff on your own.   The IA's signature at annual basically blesses things that came before that, but it still won't stop somebody else from demanding that something be undone or removed before they'll sign it off.   Even, "my FSDO said it was okay" may not work in a different district, even if you have something in writing from the previous FSDO.  If you find a good A&P/IA/shop that you like working with, keep them as long as you can.

When I was a teenage lineboy at a US flying club in Europe, our DPE was a German lady whose husband was a PanAm 747 Captain and ex-AF fighter pilot.   They had a 1960 Cessna 210, and the airspeed indicator was out of an F-104 that her husband had scrounged when he was in the AF.  It had a piece of red tape where the redline should be, which was all it needed to be legal.   They always thought it was cool to have that in there, and I always thought it was cool, too.   They had a place here in AZ that they had moved back to and I used to see them once in a while, as she was still a DPE operating out of Goodyear airport.    The last time I talked to her several years ago she was an angry hen because her new IA had made her take out that ASI and replace it with one that had all of the color arcs, etc.   Nobody had bothered her about that ASI for over fifty years, but she finally ran across somebody who wouldn't sign it off unless it had all of the markings on it.   I wish I'd had my IA at the time, but I didn't, so couldn't help her.   

So, yeah, you're always at the mercy of the next guy.   It may not matter at all who said what or when or how at any time in the past.    The entire VARMA program is an effort to try to help mitigate that at least from a parts substitution perspective, but it won't help if somebody has a problem with an owner-performed repair, like wiring, or something like that.

 

[MikeOH]

3 hours ago, hammdo said:

Fix landing light wiring’ is an example of the type of repair - then Coleal ruling states that the list in preventative maintenance are actually examples…

OK, so the legality of the repair relies on the Coleal LOI, not a specific FAR reference.

Thanks.

[Hank]

3 hours ago, EricJ said:

Yup.   This is why getting an A&P/IA that will work with you is important if you want to do more stuff on your own.   The IA's signature at annual basically blesses things that came before that, but it still won't stop somebody else from demanding that something be undone or removed before they'll sign it off.   Even, "my FSDO said it was okay" may not work in a different district, even if you have something in writing from the previous FSDO.  If you find a good A&P/IA/shop that you like working with, keep them as long as you can.

When I was a teenage lineboy at a US flying club in Europe, our DPE was a German lady whose husband was a PanAm 747 Captain and ex-AF fighter pilot.   They had a 1960 Cessna 210, and the airspeed indicator was out of an F-104 that her husband had scrounged when he was in the AF.  It had a piece of red tape where the redline should be, which was all it needed to be legal.   They always thought it was cool to have that in there, and I always thought it was cool, too.   They had a place here in AZ that they had moved back to and I used to see them once in a while, as she was still a DPE operating out of Goodyear airport.    The last time I talked to her several years ago she was an angry hen because her new IA had made her take out that ASI and replace it with one that had all of the color arcs, etc.   Nobody had bothered her about that ASI for over fifty years, but she finally ran across somebody who wouldn't sign it off unless it had all of the markings on it.   I wish I'd had my IA at the time, but I didn't, so couldn't help her.   

So, yeah, you're always at the mercy of the next guy.   It may not matter at all who said what or when or how at any time in the past.    The entire VARMA program is an effort to try to help mitigate that at least from a parts substitution perspective, but it won't help if somebody has a problem with an owner-performed repair, like wiring, or something like that.

 

I've heard of a FSDO approving a 337, then the owner relocated and the new FSDO didn't like it and the modification had to be removed and restored to original condition. Stupid!!

[Hank]

9 hours ago, Hank said:

The mechanic said "wire broken at the alternator." I haven't seen it yet, need to get back up there.

And thanks to a great ride in a nice J, I'm back home and my C has been put to bed.

[EricJ]

10 hours ago, MikeOH said:

OK, so the legality of the repair relies on the Coleal LOI, not a specific FAR reference.

Thanks.

Pretty much.   A legal opinion letter from an FAA attorney written specifically to help interpret a reg has a ton of weight.   If you stand in front of a judge and say you relied on this legal opinion from the FAA to help guide your actions, that's a pretty strong defense.   The downside is the judge may not agree with how far somebody may be willing to go with their interpretation, e.g., overhauling a motor is probably not covered by Coleal.   So care must be taken in deciding how far one is willing to go with it, and the Coleal letter even says that pilots must exercise "good judgement" in determining what is or isn't Preventive Maintenance.    It's something more than what is listed in Part 43 Appendix A(c), but how much more is not defined.

[Paul Thomas]

1 hour ago, EricJ said:

Pretty much.   A legal opinion letter from an FAA attorney written specifically to help interpret a reg has a ton of weight.   If you stand in front of a judge and say you relied on this legal opinion from the FAA to help guide your actions, that's a pretty strong defense.   The downside is the judge may not agree with how far somebody may be willing to go with their interpretation, e.g., overhauling a motor is probably not covered by Coleal.   So care must be taken in deciding how far one is willing to go with it, and the Coleal letter even says that pilots must exercise "good judgement" in determining what is or isn't Preventive Maintenance.    It's something more than what is listed in Part 43 Appendix A(c), but how much more is not defined.

The good news is that if an entity comes after you because "good judgement" was not exercised, the burden of proof will be on that entity to demonstrate you were not in compliance. That gives the letter a lot of CYA power for owners who choose to do their own maintenance.

In practice, except for oil changes, I don't touch anything without letting my IA know. I want to keep a good relationship and make annuals super easy for all involved.

[N201MKTurbo]

I have never met an FAA guy or gal who had any interest of violating you if you had good intent. If you are out of compliance, they will explain why and discuss how to get into compliance.

If they suspect you were trying to violate the regs on purpose, it is a different story.

[MikeOH]

1 hour ago, Paul Thomas said:

In practice, except for oil changes, I don't touch anything without letting my IA know. I want to keep a good relationship and make annuals super easy for all involved.

That's been my policy, as well.  Thing is, heretofore, I've had my A&P sign off on my work.  I've been too chicken to rely on the Coleal LOI, so far.  This situation is the perfect example of a repair (wire crimping) that I am completely trained, experienced, and comfortable with.  While I'd discuss with my A&P friend, I'd like to be able to perform the repair AND sign off my own work. The idea that I will have to defend myself against some future IA has stopped me.  Also, much less a concern, but one that I have considered is the effect when, someday, a future buyer, or his A&P, goes through the logs and sees a bunch of 'owner' sign-offs on items NOT specifically listed in Part 43, A, c.

[N201MKTurbo]

As a part time IA, when I’m inspecting an airplane, I couldn’t care less who did some repair. If it is done correctly with proper parts, that is all I care about. If it isn’t, then it has to be made right no matter who did it. Besides, what would I do about a crimp terminal that was crimped by an unauthorized maintainer? Cut it off and put a new one on? That would be silly. 
 

As far as the ASI is concerned, that is a harder sell. Most of the instruments are in the TC if I recall. They need to be the listed instruments or STC or TSO  replacements. 

[N201MKTurbo]

As far as a FSDO telling you that a legally signed off field approval was no longer approved, I would politely tell them to go screw themselves. 

[jetdriven]

22 hours ago, Hank said:

I've heard of a FSDO approving a 337, then the owner relocated and the new FSDO didn't like it and the modification had to be removed and restored to original condition. Stupid!!

How would the FSDO even know about a 337?  One copy goes to the Aircraft records in OKC and the owner has the other.

[jetdriven]

8 hours ago, MikeOH said:

That's been my policy, as well.  Thing is, heretofore, I've had my A&P sign off on my work.  I've been too chicken to rely on the Coleal LOI, so far.  This situation is the perfect example of a repair (wire crimping) that I am completely trained, experienced, and comfortable with.  While I'd discuss with my A&P friend, I'd like to be able to perform the repair AND sign off my own work. The idea that I will have to defend myself against some future IA has stopped me.  Also, much less a concern, but one that I have considered is the effect when, someday, a future buyer, or his A&P, goes through the logs and sees a bunch of 'owner' sign-offs on items NOT specifically listed in Part 43, A, c.

Supposedly in that Coleal letter, it says replacement of small simple parts, not requiring complex disassembly. So you could say you replaced that wire crimp according to FAR part 43 appendix a.  

[DCarlton]

On 7/7/2025 at 11:03 AM, MikeOH said:

@Hank

Glad it was the easy fix!

Curious was it a loose terminal, broken/frayed wire, or failed crimp connection?

My field wire broke at the terminal.  When repaired, shrink tubing was added to attempt to provide some strain relief.  There’s gotta be a best practice for a crimp/wire that fails as commonly as this one from vibration.  ??? 

[N201MKTurbo]

I will tie it to the big wire with a nice relaxed loop to the field.

What I see often is the field wire unsupported from the engine to the alternator.

[jetdriven]

I ran the field wire under an adel clamp to the back of the plane power alternator, and all that had shrink wrap on it, and 600 hours it hasn’t broken since.

[MikeOH]

13 hours ago, N201MKTurbo said:

What I see often is the field wire unsupported from the engine to the alternator.

THAT is exactly the problem: Unsupported wire in a high-vibration environment; it's going to fatigue fail. Not if, but when.